Summary

This exhibit introduces an official public record from the California Bureau of Real Estate titled Accusation No. H-40694 LA, filed July 7 2017 by Supervising Special Investigator Maria Suarez against Tom Nguyen. The document was produced by a state agency and is admissible as a certified public record under Evidence Code §1280. It is offered to impeach the credibility of Investigator Nguyen in connection with current enforcement actions.

Material Facts from State Filing https://www2.dre.ca.gov/hearingfiles/H40694LA_170707_P.pdf

• Filed by the California Bureau of Real Estate (Los Angeles Office).
• Accusation alleged:
  • Criminal Conviction – Vehicle Code §20002(a) (hit and run with property damage).
  • Failure to Report Conviction – violation of Bus. & Prof. Code §10186.2.
  • Failure to Disclose Conviction on renewal application – violations of §§475(b), 10177(a).
• Document requests disciplinary action against Real-Estate Broker License No. 01495604 and Mortgage Loan Originator Endorsement ID 350188.

Legal Relevance for Impeachment

• Under Evidence Code §780(f), the trier of fact may consider prior misconduct involving dishonesty or false statement when assessing witness credibility.
• The certified accusation constitutes an official acknowledgment that the respondent failed to disclose a conviction on a state license renewal, which is directly probative of veracity.
• This evidence is limited to credibility impeachment and does not assert new factual allegations beyond those found in the public record.

Cross-References

Timeline Node: July 7 2017 — Accusation No. H-40694 LA filed against Tom Nguyen (official public record).

Folder Path: /Exhibits/Impeachment_Evidence/1020.html

Tags: impeachment, credibility, public record, Evidence Code §780, Business & Professions Code §10177